The cosmetics market in the European Union is one of the biggest and most profitable in the world. For make-up companies that want to grow their business around the world, entering the EU market can be a big deal if they do it safely and legally. But for first-time sellers, it can be hard to understand EU rules about cosmetics. This step-by-step guide tells you everything you need to know to legally sell your makeup in the EU, from making it to registering it with the right people.
Why Sell Make-Up in the EU?
The EU cosmetics market is worth more than €80 billion a year and has more than 400 million customers. Makeup is one of its most active areas, with everything from indie lipstick brands to high-end eyeshadow palettes. The market in Europe has:
- There is a lot of demand from consumers for safe and high-quality goods.
- Have faith in cosmetics that have been regulated and certified
- You can grow your business by selling on sites like Etsy, Amazon, and Shopify.
But you have to follow the strict EU rules for cosmetics. To have a successful and long-lasting launch, you need to know these rules.
Understand the Legal Requirements for EU Cosmetics
The Basis: EU Regulation 1223/2009
All cosmetic products sold in the EU must comply with Regulation (EC) No 1223/2009, which governs:
- Limits on ingredients
- Checking for safety
- Packaging and labeling
- Watching the market after it has opened
- CPNP product notification
This rule makes sure that products are safe for people to use when they are used in normal or reasonably expected ways.
Role of the Responsible Person (RP)
You need to name a Responsible Person (RP) who lives in the EU before you can enter the EU market. This could be:
- A business, such as Certified Cosmetics
- A legal representative
- The importer and distributor
The RP is in charge of making sure that everything is done right, notifying the CPNP, keeping safety records, and dealing with any problems that come up after the market.
Step 1: Prepare Your Product Formula
Check Ingredient Restrictions
Make sure your formula is safe and legal before you do anything else:
- Look in the CosIng (Cosmetic Ingredient) database
- Do not use any ingredients that are banned or limited by Annex II and Annex III of the regulation.
- Make sure that your colors, preservatives, and scents meet EU standards.
It’s very important to use colorants and preservatives that have been approved ahead of time in makeup like foundation, blush, and mascara.
Step 2: Conduct Cosmetic Safety Assessment (CPSR)
What Is a CPSR, and Why You Need One
You need to get a Cosmetic Product Safety Report (CPSR) before you can sell your product. A qualified safety assessor must do this because it is required by law.
The CPSR looks at:
- Profiles of toxicology
- Concentrations of ingredients
- Use and exposure as planned
- Interaction with packaging
What the CPSR Includes
There are two parts to the CPSR:
Part A: Information about the product (formulation, exposure, and toxicological data)
Part B: The assessor’s safety assessment, conclusion, and certification
This report is an important part of your PIF and is needed for each different formulation.
How Certified Cosmetics Supports Your CPSR
Certified Cosmetics helps streamline this process by:
- Looking over your formulation
- Getting toxicological data
- Working with licensed evaluators
- Giving a CPSR that is compliant and ready to use
Step 3: Compile Your Product Information File (PIF)
The Product Information File (PIF) is a complete file that has all the paperwork for your cosmetic product. It must be easy to get to for at least ten years after the last batch was sold.
What Goes into a PIF for Make-Up?
Your PIF should have:
- The CPSR: information about the product and how it was made
- Method of production and compliance with GMP
- Art for labels and packaging
- Results of microbiological and stability tests
- Proof that any claims are true (for example, “long-lasting” or “hypoallergenic”)
Step 4: Notify Your Product on the CPNP
What is the CPNP?
The European Commission runs the Cosmetic Product Notification Portal (CPNP), which is an online platform. You have to tell each cosmetic product about itself before you sell it.
What You Need to Submit
- Name and type of product
- RP information
- Complete formulation
- Information about the label Product picture
You will get a notification ID after you send in your request. This process doesn’t cost anything.
Step 5: Create Compliant Labels and Packaging
Not only is packaging and labeling important for branding, but it’s also important for following the law.
Mandatory Labeling Elements
All labels on makeup products must show:
- List of ingredients in INCI
- What the product does (like eyeliner or lipstick)
- Total amount
- Date of minimum durability or PAO (Period After Opening)
- Warnings and instructions for use (like “Keep out of eyes”)
- Number of the batch or lot
- Name and address of the person in charge
- Country of origin (for products not from the EU)
All information must be written in the language(s) of the country where the product is sold.
Step 6: Post-Market Responsibilities
Cosmetovigilance & Product Monitoring
You have to keep an eye on the safety of your product when people use it in the real world.
Responsibilities include:
- Telling the authorities about Serious Undesirable Effects (SUEs)
- Keeping track of all complaints
- If you change any ingredients, packaging, or suppliers, you need to update your PIF.
- If asked, working with local inspections
If you don’t do your post-market duties, you could get a fine, a recall, or a ban on your product.
Step 7: Optional Certification (e.g. COSMOS)
Many brands go after COSMOS, NATRUE, or vegan certifications to gain more trust from customers, even though they don’t have to.
- To get these certifications, you need:
- Ingredients that are natural or organic
- Formulas that break down in nature
- Packaging that is good for the environment and people
- Clear supply chains
For makeup, this could mean using natural alternatives instead of silicones or synthetic colorants.
Frequently Asked Questions (FAQ)
Q1. Do I need a separate CPSR for each shade of lipstick?
Not all the time. If the base formula is the same and the pigments are only different within an approved range, one CPSR can cover more than one shade if the right paperwork is in place.
Q2. Can I sell make-up on Etsy without full compliance?
No. It is required that all make-up, even handmade or made in small batches, follow Regulation 1223/2009.
Q3. How long does it take to get a CPSR and PIF?
It usually takes 7 to 14 business days with all the information. Missing ingredient data or wrong labels are two common reasons for delays.
Q4. Is stability testing required for make-up?
Yes. You have to show that your product stays safe and works well for the time it is supposed to be on the shelf. We accept both accelerated and real-time testing methods.
Q5. Can I do the CPSR myself?
No. Only a certified safety assessor with a background in toxicology or dermatology can legally write and sign the CPSR.
Conclusion: Compliance is Your First Step Toward Success
It’s not just about being creative with makeup in the EU; it’s also a legal duty to be safe, open, and responsible. Every step, from making the product to writing down the details, must follow EU law.
Don’t go through it by yourself. Certified Cosmetics can help you make your CPSR, put together your PIF, check your labels, and tell the CPNP about your products. This makes sure that you are fully compliant and ready to sell.
Get Started with a CPSR for Make-Up. Explore More Compliance Services at Certified Cosmetics
